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ATV/OFMC Regulations ATV/OFMC Workshop July 21, 2004 Linc Wehrly

ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

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Page 1: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Regulations

ATVOFMC Workshop

July 21 2004

Linc Wehrly

Off-Highway Motorcycle (OFMC) Standards

Table 1 of sect1051105 ndash Exhaust Emission Standards for Off-Highway Motorcycles (gkm)

Model Year Phase-in (percent)

Emission Standards Maximum allowable family emission limits

HC+NOx CO HC+NOx CO

2006 50 20 25 20 50

2007 and later

100 20 25 20 50

bull Averaging banking and trading for HC+NOx and CO bull Competition exemption (sect1051620) bull Minimum useful life of 10000 km or 5years

Alternative OFMC Standards Alternative Exhaust Emission Standards for Off-Highway Motorcycles (gkm)

Model Year Phase-in (percent)

Emission Standards

HC+NOx CO

2007 100 40 35

bull No competition exemption bull At least 10 of models must have four of the following

ndash Absence of headlight or other lights ndash Absence of spark arrester ndash Absence of a manufacturer warranty ndash Suspension travel greater than 10 inches ndash Engine displacement greater than 50 cc ndash Absence of a functional seat

bull Averaging and banking for HC+NOx only ndash No trading

OFMC Less Than 70 cc Emission Standards

bull OFMC with engines less than 70 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for Off-Highway Motorcycles Less Than 70 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

161 519 322 --

161 519 322 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

OFMC Test Procedures

bull Test cycle ndash Motorcycles under 170 cc

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

ndash Motorcycles over 170 cc bull Use Class II amp III highway motorcycle cycle (Appendix I to

Part 86 paragraph (b))

bull Can test motorcycles with either knobby tire or road tire

bull Same test procedures as for highway motorcycles

ATV Standards Table 1 of sect1051107 ndash Exhaust Emission Standards for ATVs (gkm)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

15 35 20 --

15 35 20 --

Maximum allowable family emission limits

bull Averaging banking and trading allowed for HC+NOx only bull Competition exemption (sect1051620) bull Minimum useful life of 10000 km 500 hours or 5 years

ATVs Less Than 100 cc Emission Standards

bull ATVs with engines less than 100 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for ATVs Less Than 100 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

250 500 400 --

250 500 400 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km 250 hours or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Optional Exhaust Emission Standards for ATVs

Table 1 of sect1051145 ndash Optional Exhaust Emission Standards for ATVs (gkW-hr) Engine

Displacement Model Year Phase-in

(percent) Emissions Standards Maximum

allowable family

emission limits HC+NOx CO HC+NOx

lt225 cc 2006 50 161 400 322 2007 and 2008 100 161 400 322

m225 cc 2006 50 134 400 322 2007 and 2008 100 134 400 322

bull Can only be used for model years before 2009 bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

bull Emission credits can not be exchanged between optional standards and sect1051107 standards or between engines above and below 225 cc

ATV Test Procedures

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

bull For optional ATV standards use the engine-based 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Mode No Engine Speed ( of max test speed)

Torque ( of max test torque

at test speed)

Minimum time in mode (minutes)

Weighting factors

1 85 100 50 009 2 85 75 50 020 3 85 50 50 029 4 85 25 50 030 5 85 10 50 007 6 Idle 0 50 005

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 2: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Off-Highway Motorcycle (OFMC) Standards

Table 1 of sect1051105 ndash Exhaust Emission Standards for Off-Highway Motorcycles (gkm)

Model Year Phase-in (percent)

Emission Standards Maximum allowable family emission limits

HC+NOx CO HC+NOx CO

2006 50 20 25 20 50

2007 and later

100 20 25 20 50

bull Averaging banking and trading for HC+NOx and CO bull Competition exemption (sect1051620) bull Minimum useful life of 10000 km or 5years

Alternative OFMC Standards Alternative Exhaust Emission Standards for Off-Highway Motorcycles (gkm)

Model Year Phase-in (percent)

Emission Standards

HC+NOx CO

2007 100 40 35

bull No competition exemption bull At least 10 of models must have four of the following

ndash Absence of headlight or other lights ndash Absence of spark arrester ndash Absence of a manufacturer warranty ndash Suspension travel greater than 10 inches ndash Engine displacement greater than 50 cc ndash Absence of a functional seat

bull Averaging and banking for HC+NOx only ndash No trading

OFMC Less Than 70 cc Emission Standards

bull OFMC with engines less than 70 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for Off-Highway Motorcycles Less Than 70 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

161 519 322 --

161 519 322 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

OFMC Test Procedures

bull Test cycle ndash Motorcycles under 170 cc

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

ndash Motorcycles over 170 cc bull Use Class II amp III highway motorcycle cycle (Appendix I to

Part 86 paragraph (b))

bull Can test motorcycles with either knobby tire or road tire

bull Same test procedures as for highway motorcycles

ATV Standards Table 1 of sect1051107 ndash Exhaust Emission Standards for ATVs (gkm)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

15 35 20 --

15 35 20 --

Maximum allowable family emission limits

bull Averaging banking and trading allowed for HC+NOx only bull Competition exemption (sect1051620) bull Minimum useful life of 10000 km 500 hours or 5 years

ATVs Less Than 100 cc Emission Standards

bull ATVs with engines less than 100 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for ATVs Less Than 100 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

250 500 400 --

250 500 400 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km 250 hours or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Optional Exhaust Emission Standards for ATVs

Table 1 of sect1051145 ndash Optional Exhaust Emission Standards for ATVs (gkW-hr) Engine

Displacement Model Year Phase-in

(percent) Emissions Standards Maximum

allowable family

emission limits HC+NOx CO HC+NOx

lt225 cc 2006 50 161 400 322 2007 and 2008 100 161 400 322

m225 cc 2006 50 134 400 322 2007 and 2008 100 134 400 322

bull Can only be used for model years before 2009 bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

bull Emission credits can not be exchanged between optional standards and sect1051107 standards or between engines above and below 225 cc

ATV Test Procedures

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

bull For optional ATV standards use the engine-based 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Mode No Engine Speed ( of max test speed)

Torque ( of max test torque

at test speed)

Minimum time in mode (minutes)

Weighting factors

1 85 100 50 009 2 85 75 50 020 3 85 50 50 029 4 85 25 50 030 5 85 10 50 007 6 Idle 0 50 005

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 3: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Alternative OFMC Standards Alternative Exhaust Emission Standards for Off-Highway Motorcycles (gkm)

Model Year Phase-in (percent)

Emission Standards

HC+NOx CO

2007 100 40 35

bull No competition exemption bull At least 10 of models must have four of the following

ndash Absence of headlight or other lights ndash Absence of spark arrester ndash Absence of a manufacturer warranty ndash Suspension travel greater than 10 inches ndash Engine displacement greater than 50 cc ndash Absence of a functional seat

bull Averaging and banking for HC+NOx only ndash No trading

OFMC Less Than 70 cc Emission Standards

bull OFMC with engines less than 70 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for Off-Highway Motorcycles Less Than 70 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

161 519 322 --

161 519 322 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

OFMC Test Procedures

bull Test cycle ndash Motorcycles under 170 cc

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

ndash Motorcycles over 170 cc bull Use Class II amp III highway motorcycle cycle (Appendix I to

Part 86 paragraph (b))

bull Can test motorcycles with either knobby tire or road tire

bull Same test procedures as for highway motorcycles

ATV Standards Table 1 of sect1051107 ndash Exhaust Emission Standards for ATVs (gkm)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

15 35 20 --

15 35 20 --

Maximum allowable family emission limits

bull Averaging banking and trading allowed for HC+NOx only bull Competition exemption (sect1051620) bull Minimum useful life of 10000 km 500 hours or 5 years

ATVs Less Than 100 cc Emission Standards

bull ATVs with engines less than 100 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for ATVs Less Than 100 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

250 500 400 --

250 500 400 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km 250 hours or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Optional Exhaust Emission Standards for ATVs

Table 1 of sect1051145 ndash Optional Exhaust Emission Standards for ATVs (gkW-hr) Engine

Displacement Model Year Phase-in

(percent) Emissions Standards Maximum

allowable family

emission limits HC+NOx CO HC+NOx

lt225 cc 2006 50 161 400 322 2007 and 2008 100 161 400 322

m225 cc 2006 50 134 400 322 2007 and 2008 100 134 400 322

bull Can only be used for model years before 2009 bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

bull Emission credits can not be exchanged between optional standards and sect1051107 standards or between engines above and below 225 cc

ATV Test Procedures

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

bull For optional ATV standards use the engine-based 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Mode No Engine Speed ( of max test speed)

Torque ( of max test torque

at test speed)

Minimum time in mode (minutes)

Weighting factors

1 85 100 50 009 2 85 75 50 020 3 85 50 50 029 4 85 25 50 030 5 85 10 50 007 6 Idle 0 50 005

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 4: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

OFMC Less Than 70 cc Emission Standards

bull OFMC with engines less than 70 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for Off-Highway Motorcycles Less Than 70 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

161 519 322 --

161 519 322 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

OFMC Test Procedures

bull Test cycle ndash Motorcycles under 170 cc

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

ndash Motorcycles over 170 cc bull Use Class II amp III highway motorcycle cycle (Appendix I to

Part 86 paragraph (b))

bull Can test motorcycles with either knobby tire or road tire

bull Same test procedures as for highway motorcycles

ATV Standards Table 1 of sect1051107 ndash Exhaust Emission Standards for ATVs (gkm)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

15 35 20 --

15 35 20 --

Maximum allowable family emission limits

bull Averaging banking and trading allowed for HC+NOx only bull Competition exemption (sect1051620) bull Minimum useful life of 10000 km 500 hours or 5 years

ATVs Less Than 100 cc Emission Standards

bull ATVs with engines less than 100 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for ATVs Less Than 100 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

250 500 400 --

250 500 400 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km 250 hours or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Optional Exhaust Emission Standards for ATVs

Table 1 of sect1051145 ndash Optional Exhaust Emission Standards for ATVs (gkW-hr) Engine

Displacement Model Year Phase-in

(percent) Emissions Standards Maximum

allowable family

emission limits HC+NOx CO HC+NOx

lt225 cc 2006 50 161 400 322 2007 and 2008 100 161 400 322

m225 cc 2006 50 134 400 322 2007 and 2008 100 134 400 322

bull Can only be used for model years before 2009 bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

bull Emission credits can not be exchanged between optional standards and sect1051107 standards or between engines above and below 225 cc

ATV Test Procedures

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

bull For optional ATV standards use the engine-based 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Mode No Engine Speed ( of max test speed)

Torque ( of max test torque

at test speed)

Minimum time in mode (minutes)

Weighting factors

1 85 100 50 009 2 85 75 50 020 3 85 50 50 029 4 85 25 50 030 5 85 10 50 007 6 Idle 0 50 005

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

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ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

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ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

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ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 5: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

OFMC Test Procedures

bull Test cycle ndash Motorcycles under 170 cc

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

ndash Motorcycles over 170 cc bull Use Class II amp III highway motorcycle cycle (Appendix I to

Part 86 paragraph (b))

bull Can test motorcycles with either knobby tire or road tire

bull Same test procedures as for highway motorcycles

ATV Standards Table 1 of sect1051107 ndash Exhaust Emission Standards for ATVs (gkm)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

15 35 20 --

15 35 20 --

Maximum allowable family emission limits

bull Averaging banking and trading allowed for HC+NOx only bull Competition exemption (sect1051620) bull Minimum useful life of 10000 km 500 hours or 5 years

ATVs Less Than 100 cc Emission Standards

bull ATVs with engines less than 100 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for ATVs Less Than 100 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

250 500 400 --

250 500 400 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km 250 hours or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Optional Exhaust Emission Standards for ATVs

Table 1 of sect1051145 ndash Optional Exhaust Emission Standards for ATVs (gkW-hr) Engine

Displacement Model Year Phase-in

(percent) Emissions Standards Maximum

allowable family

emission limits HC+NOx CO HC+NOx

lt225 cc 2006 50 161 400 322 2007 and 2008 100 161 400 322

m225 cc 2006 50 134 400 322 2007 and 2008 100 134 400 322

bull Can only be used for model years before 2009 bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

bull Emission credits can not be exchanged between optional standards and sect1051107 standards or between engines above and below 225 cc

ATV Test Procedures

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

bull For optional ATV standards use the engine-based 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Mode No Engine Speed ( of max test speed)

Torque ( of max test torque

at test speed)

Minimum time in mode (minutes)

Weighting factors

1 85 100 50 009 2 85 75 50 020 3 85 50 50 029 4 85 25 50 030 5 85 10 50 007 6 Idle 0 50 005

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

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ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

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ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

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ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

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ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

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ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

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ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

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ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 6: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATV Standards Table 1 of sect1051107 ndash Exhaust Emission Standards for ATVs (gkm)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

15 35 20 --

15 35 20 --

Maximum allowable family emission limits

bull Averaging banking and trading allowed for HC+NOx only bull Competition exemption (sect1051620) bull Minimum useful life of 10000 km 500 hours or 5 years

ATVs Less Than 100 cc Emission Standards

bull ATVs with engines less than 100 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for ATVs Less Than 100 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

250 500 400 --

250 500 400 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km 250 hours or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Optional Exhaust Emission Standards for ATVs

Table 1 of sect1051145 ndash Optional Exhaust Emission Standards for ATVs (gkW-hr) Engine

Displacement Model Year Phase-in

(percent) Emissions Standards Maximum

allowable family

emission limits HC+NOx CO HC+NOx

lt225 cc 2006 50 161 400 322 2007 and 2008 100 161 400 322

m225 cc 2006 50 134 400 322 2007 and 2008 100 134 400 322

bull Can only be used for model years before 2009 bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

bull Emission credits can not be exchanged between optional standards and sect1051107 standards or between engines above and below 225 cc

ATV Test Procedures

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

bull For optional ATV standards use the engine-based 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Mode No Engine Speed ( of max test speed)

Torque ( of max test torque

at test speed)

Minimum time in mode (minutes)

Weighting factors

1 85 100 50 009 2 85 75 50 020 3 85 50 50 029 4 85 25 50 030 5 85 10 50 007 6 Idle 0 50 005

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 7: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVs Less Than 100 cc Emission Standards

bull ATVs with engines less than 100 cc have option to certify to engine-based exhaust standards (sect1051615)

Exhaust Emission Standards for ATVs Less Than 100 cc (gkW-hr)

Model Year

2006

2007 and later

Phase-in (percent)

50

100

Emission Standards

HC+NOx CO HC+NOx CO

250 500 400 --

250 500 400 --

Maximum allowable family emission limits

bull Averaging banking and trading for HC+NOx only bull Minimum useful life of 5000 km 250 hours or 5 years bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Optional Exhaust Emission Standards for ATVs

Table 1 of sect1051145 ndash Optional Exhaust Emission Standards for ATVs (gkW-hr) Engine

Displacement Model Year Phase-in

(percent) Emissions Standards Maximum

allowable family

emission limits HC+NOx CO HC+NOx

lt225 cc 2006 50 161 400 322 2007 and 2008 100 161 400 322

m225 cc 2006 50 134 400 322 2007 and 2008 100 134 400 322

bull Can only be used for model years before 2009 bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

bull Emission credits can not be exchanged between optional standards and sect1051107 standards or between engines above and below 225 cc

ATV Test Procedures

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

bull For optional ATV standards use the engine-based 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Mode No Engine Speed ( of max test speed)

Torque ( of max test torque

at test speed)

Minimum time in mode (minutes)

Weighting factors

1 85 100 50 009 2 85 75 50 020 3 85 50 50 029 4 85 25 50 030 5 85 10 50 007 6 Idle 0 50 005

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 8: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Optional Exhaust Emission Standards for ATVs

Table 1 of sect1051145 ndash Optional Exhaust Emission Standards for ATVs (gkW-hr) Engine

Displacement Model Year Phase-in

(percent) Emissions Standards Maximum

allowable family

emission limits HC+NOx CO HC+NOx

lt225 cc 2006 50 161 400 322 2007 and 2008 100 161 400 322

m225 cc 2006 50 134 400 322 2007 and 2008 100 134 400 322

bull Can only be used for model years before 2009 bull Engine-based test cycle

ndash 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

bull Emission credits can not be exchanged between optional standards and sect1051107 standards or between engines above and below 225 cc

ATV Test Procedures

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

bull For optional ATV standards use the engine-based 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Mode No Engine Speed ( of max test speed)

Torque ( of max test torque

at test speed)

Minimum time in mode (minutes)

Weighting factors

1 85 100 50 009 2 85 75 50 020 3 85 50 50 029 4 85 25 50 030 5 85 10 50 007 6 Idle 0 50 005

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

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ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

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ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

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ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

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ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 9: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATV Test Procedures

bull Use Class I highway motorcycle cycle (Appendix I to Part 86 paragraph (c))

bull For optional ATV standards use the engine-based 6 Mode Duty Cycle for Recreational Vehicles (SAE J1088)

Mode No Engine Speed ( of max test speed)

Torque ( of max test torque

at test speed)

Minimum time in mode (minutes)

Weighting factors

1 85 100 50 009 2 85 75 50 020 3 85 50 50 029 4 85 25 50 030 5 85 10 50 007 6 Idle 0 50 005

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 10: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Offroad Utility Vehicles

bull Offroad utility vehicles are subject to the same requirements as ATVs

bull Offroad utility vehicles are defined as having ndash engines with displacement less than 1000 cc ndash max brake horsepower less than or equal to 30

kW (40 hp) and ndash max vehicle speed of 25 mph or higher

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

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ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

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ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

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ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

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ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

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ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

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ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

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ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

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ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 11: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Permeation Standards

bull Permeation refers to gasoline that passes through the walls of non-metal fuel tanks and hoses This permeation occurs both when the tankhose material is exposed to liquid fuel or to fuel vapor

bull Hose ndash Standard 15 gm2day ndash Temperature 23degC ndash Fuel E10 fuel ndash Testing SAE J30 test equipmentprocedures

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

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ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 12: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Permeation Standards

bull Fuel Tanks ndash Standard 15 gm2day ndash Temperature 28degC ndash Fuel E10 fuel ndash Testing preconditioning

ndash fuel soak on E10 ndash slosh testing ndash UV exposure ndash pressurevacuum testing ndash weight loss (or equivalent) test method

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 13: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Competition Exemption bull General

ndash used solely for competition ndash exemptions good for one year ndash we will not renew exemption if we determine vehicles will not be

used solely for competition ndash permanently label vehicle to clearly indicate used solely for

competition

bull OHMC ndash marketed and labeled as only for competitive use and that meet at

least four of the following criteria bull Absence of headlight or other lights bull Absence of spark arrester bull Absence of a manufacturer warranty bull Suspension travel greater than 10 inches bull Engine displacement greater than 50 cc bull Absence of a functional seat

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

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ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 14: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Competition Exemption

bull ATVs ndash The vehicle or engine may not be displayed in any public

dealership ndash Sale of the vehicle must be limited to professional racers or other

qualified racers ndash The vehicle must have performance characteristics that are

substantially superior to noncompetitive models

bull Vehicles not meeting the OHMC or ATV criteria will be exempted only in cases where manufacturers have clear and convincing evidence that the vehicles will be sold solely for competition

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

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ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

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ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

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ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

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ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

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ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

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ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

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ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

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ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 15: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Hang Tag Labels

bull Label every vehicle with a removable hang tag showing its emission characteristics relative to other models

bull Tags will include at a minimum the following information ndash manufacturerrsquos name vehicle model name engine description the

NER and a brief explanation of the scale

bull Each tag will include a normalized emission rate (NER) bull Example of OFMC NER equation

ndash NER = 2500 x (HC+NOx) for OFMCs with emissions less than or equal to 20 gkm

ndash NER = 5000 x (HC+NOx) for OFMCs with emissions greater than 20 gkm

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

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ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

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ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

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ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

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ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

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ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

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ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

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ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 16: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Flexibilities for Small Volume Manufacturers

bull Small manufacturer defined as having less than 500 employees and selling less than 5000 units (combined OFMC amp ATV)

bull Flexibilities ndash Additional lead time ndash Design-based certification ndash Broaden engine families ndash Production-line testing waiver ndash Use of assigned deterioration factors for certification ndash Using emission standards and certification from other EPA programs ndash Averaging banking and trading ndash Hardship provisions

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 17: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 1 of 18

DRAFT

Major Steps of Certification and Compliance for

2006 and Later Model Years All-terrain Vehicles and Off-highway Motorcycles

July 21 2004

This step-by-step guidance is intended to assist you in the certification process and does not replace any regulations Failure to comply with the applicable regulations can result in substantial penalties and EPA may revoke or suspend your certificates It is your responsibility to know and comply with the regulations This guidance document summarizes the major steps for EPArsquos certification and compliance programs for all-terrain vehicles (ATV) and off-highway motorcycles (OFMC) provides policy guidance where necessary and directs you to specific requirements regarding these major steps

For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately (and concurrently) addressed to and ruled on by EPA and CARB

This document contains harmonized guidance for EPA and California Air Resources Board (CARB) certification The EPA regulations that are cited throughout this document also have corresponding California regulations unless otherwise noted

Please note the citations specified in this draft document reflect the regulations as published on November 8 2002 and are subject to change through future regulatory amendments

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

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ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 18: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 2 of 18

Major Steps of Certification and Compliance for 2006 and Later Model Year ATVs and Off-Highway Motorcycles

1 Register with EPA

2 Group vehiclesengines into Engine Families (EFs)

3 Conduct emissions tests to demonstrate compliance

6 Submit application and test data to EPACARB

4 Prepare a complete application for certification

5 Submit appropriate certification fees

New manufacturers only

Pre-certification requirements

Receive EPA CertificateEO

12 Provide warranty service submit Defect Report (DR) and conduct recalls if any

9 Conduct Production Line Tests (PLT) if required

8 Label each new vehicleengine

7 Build vehiclesengines to certified specifications

10 Submit amendments to the application if any

11 Submit required reports (End-of-MY report etc) N

ot n

eces

sary

in th

is o

rder

Post-certification requirements

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

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ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

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ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

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ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

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ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

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ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

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ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

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ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

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ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

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ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 19: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 3 of 18

Step 1 Register with EPA

A manufacturer who is applying for the first time for US EPA emissions certification should start by registering with EPA The registration process includes

1) Send a Manufacturer Registration Letter to

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US Environmental Protection Agency 2000 Traverwood Drive Ann Arbor Michigan 48105 (Email MC-certepagov)

For CARB certification send a letter to Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

In this letter provide general information about your company your certification plans and a brief description of the new vehicles or engines that you intend to introduce into commerce in the United States The letter must also contain answers to the List of Questions designed for a new manufacturer (see Attachment 1) If the information you provide is satisfactory the Agency will inform you of your manufacturer status (eg small-volume manufacturer independent commercial importer agent of original equipment manufacturer etc) Once you obtain your status proceed to 2) below

2) Access the EPArsquos web site wwwepagovotaqcfeishtm Under ldquoNew Manufacturer Registrationrdquo section download the electronic Manufacturer Code Entry Form complete it and email it to us at omscfeisepagov EPA will send an email or a fax back to you with your companyrsquos unique identification code You only need to register once After registration if any change occurs such as company name or mail address you should submit updated information to omscfeisepagov to allow EPA to keep accurate records about your company

Manufacturer in general ldquoincludes any person who manufactures a vehicle or engine for sale in the United States or otherwise introduces a new vehicle or engine into commerce in the United States This includes importers that import vehicles or engines for resalerdquo (Ref 40 CFR sect1051801)

Step 2 Group VehiclesEngines into Engine Families (EF)

An Engine Family (EF) is the basic unit used by EPA to issue a certificate for recreational vehicles or engines By definition an EF means a group of vehiclesengines with similar emission characteristics (40 CFR sect1051801) Emission certification must be obtained every model year regardless of whether your engine families change or not You are required to

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 20: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 4 of 18

submit a new application and pay certification fees for each EF that you intend to certify every model year

How to group vehicles or engines into Engine Families (EF)

In general you should divide your product line into families of vehiclesengines that are expected to have similar exhaust and evaporative emission characteristics throughout their useful life You may group vehiclesengines into the same engine family if they are the same in all of the following aspects (40 CFR sect1051230)

(1) The combustion cycle (2) The cooling system (water-cooled vs air-cooled) (3) Configuration of the fuel system (for example port fuel injection vs carbureted) (4) Method of air aspiration (5) The number location volume and composition of catalytic converters (6) Type of fuel (7) The number arrangement and approximate bore diameter of cylinders (8) Evaporative emission controls

Note Crankcase evaporative emissions may not be discharged directly into the ambient atmosphere from any vehicle (Ref 40 CFR sect1051115(a))

How to name an Engine Family

To facilitate the certification process EPA requests that all manufacturers use the following standardized naming convention for their engine families This consists of twelve (12) characters which identify an individual EF The following table explains in detail the naming convention for engine families of OFMCs and ATVs

Number of Characters Column Description

1 1 Model Year (eg use ldquo6rdquo if you intend to obtain a 2006 MY certificate)

3 2-4 Three letter manufacturer identification code assigned by EPA at the time you register your company with EPA

1 5 Vehicle Type (use the letter ldquoXrdquo to represent OFMC and ATVs including utility vehicles that are covered by applicable ATV regulations)

4 6-9

Displacement in cubic inches (eg 0350 0097) or liters (eg 057-the decimal point counts as a digit and the leading zero is a space) For dual or variable displacement families enter the maximum displacement For large displacement engines the displacement may be entered as XX X format (eg 121) Small engines may be entered as a XXX format (eg 072 007 007) In all cases the

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

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ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

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ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

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ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

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ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

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ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 21: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 5 of 18

displacement will be read in liters if a decimal point is entered and it will be read in cubic inches if there is no decimal point

3 10-12

Sequence characters specified by a manufacturer Enter any combination of valid characters to provide a unique identification for the engine family name It is recommended that numbers and letters be selected that minimize possible confusion

Example

(1) 5XYCX0125AE7 Where ldquo5rdquo- for 2005 MY engine family YCrdquo-manufacturer ATV or OFMC ldquo0125rdquo- displacement 125 cubic inches ldquoAE7rdquo-manufacturer specified code

(2) 6XYCX072A6B Where ldquo6rdquo-2006 MY engine family YCrdquo-manufacturer rdquo-

ATV or OFMC ldquo072rdquo-072 liter (the displacement is in liters since a decimal point is entered) ldquoA6Brdquo- manufacturer specified code

ldquoX ldquoXrdquo-

ldquoX ldquoX

At a minimum the sequence characters in combination with the other characters in the family name must provide a unique identifier for the family It is recommended but not required that the sequence characters themselves be unique for all families for a manufacturer and model year These sequence characters may be used to codify information to meet Californias requirements but they will be treated as simple sequence characters by EPAs computer software

Reference (1) VPCD-96-12 - EPA Standardized Motorcycle Engine Family and Evaporative Family

Names for the 1998 and later Model Years (2) CCD-04-01 - Update to EPA Standardized Test GroupEngine Family Name (3) 40 CFR sect1051230 How do I select engine families

Step 3 Conduct Emissions Tests to Demonstrate Compliance

The emission standards and test procedures required for 2006 and later model year ATVs and OFMCs are summarized in two tables in Attachment 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Table 2 Off-Highway Motorcycle Emission Standards and Test Requirement for 2006 and

Later MY

Two types of emission tests are required to demonstrate that vehiclesengines your company manufacturers comply with exhaust standards as specified in sect1051105 sect1051107 or sect1051145 and evaporative emission standards as specified in sect1051110

frac34 Exhaust emissions tests to measure CO NOx HC and CO2 from the exhaust frac34 Evaporative emissions tests to measure HC permeation emissions from fuel tanks and

fuel lines

For CARB off-highway recreational vehicle emission standards refer to Title 13 California Code of Regulations (13CCR) Section 2412(b) For ATVs tested under the small off-road

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

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ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

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ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

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ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

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ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

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ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

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ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

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ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

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ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

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ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

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ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 22: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 6 of 18

engine procedures refer to 13CCR Section 2403(b) These can be accessed at httpccroalcagov

Test for Exhaust Emissions

In general the core steps to test exhaust emissions include the following 1) Select an Emission-Data VehicleEngine (EDV) from each EF (Ref 40 CFR

sect1051235(b)) 2) Conduct service accumulation 3) Conduct durability tests to generate Deterioration Factors (DF) for each regulated

pollutant (Ref sect1051520) 4) Conduct emissions tests (Ref sect1051235 (a)) 5) Calculate end-of-useful life emissions (Ref sect1051240(c)(1) or (2)) 6) Demonstrate compliance with the required emission standards by comparing end-of-

useful life emissions with the applicable emission standards

For exhaust emission tests performed for vehicles on a chassis dynamometer use the appropriate equipment procedures and duty cycles as specified in 40 CFR Part 86 Subpart F For tests performed on ATV engines for emission standards set forth in sect1051145 follow the procedures in sect1051145(b)(2) and (b)(3)

For ATVs with a displacement less than 100 cc or off-highway motorcycles with displacement equal to or less than 70cc use the testing procedures described in sect1051615(d) to meet the emissions standards set forth in sect1051615(a) or (b) CA has no special alternate provisions

In certain cases you may use previously generated emission data instead of conducting new tests for a new certificate See sect1051235(c) for details

If you are a qualified small-volume manufacturer (SVM) you may use EPA-assigned DFs for your emission calculations or you may request ldquocertify-by-designrdquo instead of testing your vehicle to generate the required emissions data To ldquocertify-by-designrdquo you must show in writing to the EPA that the technology used on your vehiclesengines is sufficiently similar to the previously tested technology and that your vehiclesengines will comply with the applicable emission standards [CARB regulations have no allowance for small volume manufacturers and do not offer assigned DFs]

Reference 40 CFR sect1051235 What emission testing must I perform for my application for a certificate of

conformity 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect 1051240 How do I demonstrate that my engine family complies with exhaust emission

standards 40 CFR sect1051615 What are the special provisions for certifying small recreational engines 40 CFR sect1051145 What provisions apply only for a limited time 40 CFR sect1051250 What records must I keep and make available to EPA 40 CFR sect1051635 What provisions apply to new manufacturers that are small businesses 13CCR Section 2412(b) Off-highway recreational vehicle exhaust emission standards 13CCR Section 2403(b) Small off-road engine exhaust emission standards

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 23: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 7 of 18

Test for Evaporative (Permeation) Emissions

The evaporative hydrocarbon emissions standards are found in 40 CFR sect1051110 The direct standards are 15 grams per square meter per day (15 gm2day) for a fuel tank and 15 grams per square meter per day (15 gm2day) for all of fuel lines

There are two methods you may use to demonstrate compliance (Ref sect1051245)

1) Emission testing method as specified in sect1051515 and Figure sect1051515-1 that presents a flow chart for the permeation testing and shows the full test procedure with durability testing as well as the simplified test procedure with an applied deterioration factor

2) ldquoCertify-by-designrdquo method by showing fuel tanks and fuel lines comply with the design specifications listed in sect1051245(e)

Small volume manufacturers may use an EPA-assigned DF instead of conducting emission tests to develop a DF (Ref sect1051245(c)(1))

This requirement will not be reviewed by CARB

Reference 40 CFR sect1051501 What procedures must I use to test my vehicles or engines 40 CFR sect1051515 How do I test my fuel tank for permeation emissions 40 CFR sect1051245 How do I demonstrate that my engine family complies with evaporative emission

standards

EPACARB Audits

EPACARB may conduct certification confirmatory tests production line tests or in-use tests to measure emissions from any of your vehicles or engines within the engine family or require you to test a second vehicle or engine of the same engine family or different configuration within an engine family (Ref 40 CFR sect1051235 (d) and 40 CFR Part 1068 Subpart E)

Reference 40 CFR sect1051235(d) What emission testing must I perform for my application for a certificate of

conformity 40 CFR Part 1068 Subpart E Selective enforcement audit

Step 4 Prepare an Accurate and Complete Application Package for Certification

An application for Certification is required to be submitted for each Engine Family for a new model year This is the documentation that describes what vehicles and engines are covered by the certificate and how they comply with the emission standards and other regulatory requirements

Application Format

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

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ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

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ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

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ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

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ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

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ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

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ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

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ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

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ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

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ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 24: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 8 of 18

Instructions on the format of the Application for Certification are contained in a separate guidance - ATVOFMC Guidance 2 of 3 RECOMMENDED APPLICATION FORMAT FOR CERTIFICATION OF OFF-HIGHWAY MOTORCYCLES AND ALL-TERRAIN VEHICLES Guidance 2 provides detailed instructions regarding how to prepare an accurate and complete Application for Certification

Your application package is the primary information source of the engine family you intend to certify and it provides the basis for EPAsCARBrsquos determination of compliance with the applicable emission control regulations A complete and accurate application for certification must be submitted for each engine family prior to EPACARB issuance of a Certificate of Conformity or Executive Order

Advance EPACARB Approval Please note that manufacturers must obtain advance EPACARB approval before taking any action or submitting an application on certain items as listed below unless otherwise instructed

bull any proposed modifications to EPACARB-specified durability and emission test procedures

bull any proposed change to EPACARB-standardized vehicle emission control information (VECI) label specifications (Ref sect1051135)

bull request to become an EPA-designated small volume manufacturer (Ref sect1051635 and sect1051801) [Please note there are no small volume manufacturer provisions for CARB]

bull request for competition vehicle exemption (Ref sect1051620)

Application Amendments If prior to EPACARB certification a manufacturer needs to amend an application that has already been submitted to EPACARB due to changes that have occurred these changes must be submitted electronically to your designated EPA contact [and mailed to your designated CARB contact]

Application Package

a EPA Package Content

Manufacturers are required to send an electronic application package to EPA for certification review The package must at a minimum include

EPA Application Package Content Format 1) Application

bull A cover letter signed by an authorized representative of your company

bull Complete content of application for certification bull A Fee Payment Form bull California EO if s area is ldquoCalifornia

onlyrdquo sale

PDF

2) Data Summary Sheet

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 25: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 9 of 18

EPA and CARB are targeting on making the new database and computer system ready for the 2006 MY ATVOFMC certification program Before the system is functional manufacturers are required to use an interim Data Summary Sheet (a data input file in MS Excel format) to submit electronic data for the current EPA database

b CARB Package Content (for 2006 and later model years)

For CARB certification review manufacturers are required to mail either a CD (with cover letter) or a hardcopy application

CARB Package Content Format 1) Application

bull A cover letter with signature bull Complete content of application for certification PDF bull EPA certificate for 50 St families certified in CA

can be submitted upon issuance

Recommendations to New Manufacturers To expedite EPACARB review we strongly recommend that a manufacturer who is new to the US EPACARB certification and compliance procedures discuss certain topics with your assigned EPACARB certification representative well in advance of requesting certification These topics may include but are not limited to

bull VECI label content format and print size location and visibility You may use a photo copy of the label to show this

bull averaging trading and banking plans if any bull warranty statements bull emission-related maintenance instructions you intend to provide to the owners of your

vehiclesengines

Reference sect1051201 What are the general requirements for submitting a certification application sect1051205 What must I include in my application sect1051215 What happens after I complete my application sect1051250 What records must I keep and make available to EPA sect1051255 What decisions may EPA make regarding my certificate of conformity

Special Instructions for Data from a New Testing Facility In general if your certification test data is provided by an emission testing facility that is new to EPArsquos automotive certification program you should provide satisfactory documentation to the EPA that shows

1) the testing facility has demonstrated knowledge of the US EPA certification testing regulations has the required testing equipment and is fully compliant with the required

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

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ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

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ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

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ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

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ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

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ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 26: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 10 of 18

testing procedures contained in the Code of Federal Regulations 40 CFR Part 86 Subpart F and E or 40 CFR Part 1051 and Part 1065 and

2) the testing facility has established an initial satisfactory correlation with the Agencyrsquos testing facility or any other reputable independent US certification testing facilities andor

3) the testing facility has demonstrated continued correlation by participating periodical correlation confirmation tests among the US testing facilities and

4) the name address telephone number of the manager of the testing facility and working hour when the manager can be contacted and

5) a detailed description of the test fuel properties used for testing demonstrating compliance with the requirements of 40 CFR 86513-94 or 40 CFR 1065 subpart C as applicable and

6) a detailed description of the dynamometer and exhaust gas sampling demonstrating compliance with the requirements of 40 CFR 86508-78 through 511-90 or 40 CFR 1065110 as applicable and

7) a detailed description of calibration gases used to calibrate the exhaust gas analyzer demonstrating compliance with the requirements of 40 CFR 86514-78 or the applicable requirements in 40 CFR 1065 Subpart D and

8) a description of the dynamometer driving schedule used for certification testing which demonstrates compliance with the requirements of 40 CFR 86515-78 or the applicable requirements contained in 40 CFR 1051 and 1065 and

9) a description of the method and frequency of calibrating the equipment used for certification testing which demonstrates compliance with the requirements of 40 CFR 86516 through 86526 or the applicable requirements in 40 CFR 1065

EPA may ask you to provide any additional information including but not limited to a description of the test procedure used for certification testing raw test data logs records of dynamometer driving traces original logs for service accumulation photos of testing equipment raw test results and calculations correlation test information and analysis howwhenwhere and by whom the vehiclesengines were tested etc

Step 5 Pay Appropriate Certification Fees

EPA requires payment of a certification fee (40 CFR Subpart Y 852408(c)) in advance of any EPA services related to certification activities The application for certification should not be submitted until the certification fee is paid and a manufacturer has completed all required emission tests EPA will accept and begin work on the application only after the fee is received Proper and timely fee payments will minimize delays for both the manufacturer and EPA A fee payment is required for each certificate issued by EPA

The current EPA certification fee schedule is (Effective Period 71204 ndash 123105) Category Certificate Type Fees Per Certificate

ATV amp Off-highway Motorcycles All Types $826 On-Highway Motorcycles Including ICIs All Types $2414

The fee schedule will change for each model year as it is adjusted for inflation and to reflect changes in the numbers of certificate issued Please visit wwwepagovotaqfeeshtm for the most current information and the exact fees you need to pay for a specific model year

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 27: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 11 of 18

The fee is made payable to the US Environmental Protection Agency according to the procedure described in EPA guidance letter CCD-04-14 and must be submitted with a Fee Filing Form which is available at wwwepagovotaqfeeshtm Allow approximately two weeks for the EPA to receive the fee and log your payment into our database Proof of payment is based on the payment being received by EPA and its entry into the EPA database

Current CARB regulations do not require off-road certification fees

Step 6 Submit the Application Package for Certification

Before the EPACARB database is functional there are three different submission procedures depending on where you intend to sell the vehiclesengines covered by the certificate in California only in all 50 states or in the US except California (ldquo49 statesrdquo)

1) For a ldquoCalifornia onlyrdquo certificate submit your application to CARB first and obtain their Executive Order (EO) prior to applying for a Federal certificate EPA in general issues a Federal certificate only after a California EO is issued

2) For a ldquo50 statesrdquo certificate submit your application to EPA and CARB concurrently 3) For a ldquo49 statesrdquo certificate submit your application to EPA only

Current Application Submission Process Manufacturers are required to either email or mail your electronic application package (using any electronic media such as a CD) to the EPA Please be aware that the confidentiality of email transmissions cannot currently be guaranteed so if this is of particular concern to you you may prefer to send applications via regular mail Send the package to the attention of your designated EPA certification representative at

MotorcycleATV Certification Team Certification and Compliance Division Office of Transportation and Air Quality US EPA 2000 Traverwood Drive Ann Arbor MI 48105

Manufacturers are required to mail either CD (with cover letter) or hard copy application to CARB

Mr Allen Lyons Chief Mobile Source Operations Division Air Resources Board 9480 Telstar Ave Suite 4 El Monte CA 91734-2301

Future Plans ndash For information only The EPA Certification and Compliance Division is currently redesigning its computer system The new system architecture will allow EPA and CARB to share data and will permit manufacturers to submit their data and application package in one of three ways

1) Upload manufacturersrsquo data and files to the EPA system via Web browser Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 28: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 12 of 18

Manufacturers can create their data with whatever tool they wish as long as the output is in XML format as specified by EPA (EPA will provide the XML schema) and then upload to EPArsquos system using a standard web browser

2) Provide data and files using interactive Web forms Manufacturers can use the EPA developed web forms to interactively input their data field-by-field and to attach their PDF application to the input form using a standard web browser

3) Using computer-to-computer data transmittal Manufacturers can send their XML formatted data computer-to-computer without the use of human intervention through the Internet

The ATVOFMCHMC program is a pilot for this proposed new computer system The EPACARB is planning to have the system ready and start collecting data for the program in a near future and the instructions on ldquohow tordquo will be provided

Step7 Build Vehicles According to Certified Specifications

After receiving an EPA certificate andor CARB Executive Order (EO) manufacturers must take the necessary steps to assure that the production vehicles or engines are within the scope of an issued certificateEO with respect to materials engine design drivetrain fuel system emission control system strategy and components exhaust after-treatment devices vehicle mass or any other device and component that can reasonably be expected to influence exhaust emissions

Step 8 Label Each New Vehicle Produced

In general three labels are required for each new vehicle you produced bull a permanent and unique Vehicle Identification Number (VIN) (sect1051135(a)) bull a permanent Vehicle Emission Control Information (VECI) label (sect1051135(b) to (e)) and bull a removable consumer information hang-tag which provides relative emission information in

terms of normalized emission rate (NRE) in comparison with emissions of other vehicles (sect1051135(g))

[For CARB the certifying manufacturerrsquos name must be indicated on the VECI label]

Reference 40 CFR sect1051135 How must I label and identify the vehicles I produce 40 CFR sect1051645 What special provisions apply to branded engines

Step 9 Conduct Production Line Tests (PLT)

Engine families except those complying with the Phase I emissions standards and not certified to Family Emission Limits (FELs) (40 CFR sect1051145(c)) are subject to the PLT requirements (Ref 40 CFR Part 1051 Subpart D)

Small volume manufacturers are exempted for the PLT requirements (40 CFR sect1051301(a))

Advance EPA Approvals

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 29: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 13 of 18

When PLT requirements are applicable you must get EPArsquos advance approval for the following items unless otherwise instructed

bull use of an alternative PLT program (sect1051301(d)) bull reduced PLT tests after two years of good records (sect1051301 (e)) bull methods to handle a malfunctioned PLT vehicle or engine (sect1051305(c)) bull retest after an invalid test (sect1051305(g))

PLT Procedures Manufacturers who are subject to PLT requirements must conduct PLT after receiving a certificate during the model yearrsquos production period and use the procedures described in sect1051301-315

Failure Reports If any single tested vehicle or an engine family fails the manufacturer is required to submit a failure report to EPA as indicated in the following chart

PLT Failure Case Certificate Status Remedy Action Report Timing a An individual

vehicleengine fails Automatically suspended for the vehicleengine See sect1051320 Report in the end-of-

test period report

b An engine family fails

Suspended in whole or in part for the EF EPA case-by-case decision

See sect1051325 amp sect1051335

Report within 10 days (sect1051315(g))

EPA will review the report and notify the manufacturer of its decision that may include but is not limited to suspending or revoking the certificate amending FELs etc To reinstate a suspended certificate a manufacturer must make corrections to ensure their vehiclesengines meet emissions standards set forth in sect1051105 sect1051107 and sect1051145

Periodic Reports Manufacturers subject to PLT are required to submit the following periodic reports (Ref sect1051310)

Project EF Sales Production Period Test Period Required Report Note

euml 1600 units = 12 Months 3 Months 1 report 3 mo Submit periodical

electronic report within 30 days of the end of each test period

12 Months Equal segment 70 ndash 125 daysSegment 1 reportsegment

1600 units Any Whole MY 1 report MY

EPA has the authority to revoke a certificate if a manufacturer does not meet the reporting requirements (sect1051340(a)(1)) Manufacturers must also keep all paper records as specified in sect1051350 for one full year after all required testing has been completed for that engine family in a model year

Reference 40 CFR sect1051301 When must I test my production-line vehicles or engines 40 CFR sect1051305 How must I prepare and test my production-line vehicles or engines

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 30: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 14 of 18

40 CFR sect1051310 How must I select vehicles or engines for production-line testing 40 CFR sect1051315 How do I know when my engine family fails the production-line testing

requirements 40 CFR sect1051320 What happens if one of my production-line vehicles or engines fails to meet

emission standards 40 CFR sect1051325 What happens if an engine family fails the production-line requirements 40 CFR sect1051330 May I sell vehicles from an engine family with a suspended certificate of

conformity 40 CFR sect1051335 How do I ask EPA to reinstate my suspended certificate 40 CFR sect1051340 When may EPA revoke my certificate under this subpart and how may I sell

these vehicles again 40 CFR sect1051345 What production-line testing records must I send to EPA 40 CFR sect1051350 What records must I keep

Step 10 Submit Amendments to the Application

You must report to EPACARB any changes to the application made after EPACARB has issued a certificateEO for that engine family Minor typographical corrections may be submitted directly to the designated EPACARB officer

There are three circumstances under which you must amend your application prior to taking the action These actions are

1) add a new vehicle configuration to the certified engine family or 2) modify a FEL for a certified engine family [for CARB designated standard change is not

allowed once vehicles are certified] or 3) change a vehicle already included in the engine family in a way that may affect emissions

Under these circumstances you will need to submit a request to EPACARB to amend the application and include the information required in 40 CFR 1051225(b) Upon submitting this information to EPACARB you may take the requested action however EPACARB still has the authority to request more information or to deny the requested action Depending upon the change EPACARB may issue a revised certificate or Executive Order

For CARB the amendments should be submitted by mail in the form of a CD with a cover letter or a hardcopy

Reference 40 CFR sect1051220 How do I amend the maintenance instructions in my application 40 CFR sect1051215 What happens after I complete my application 40 CFR sect1051225 How do I amend my application for certification to include new or modified vehicles

or to change an FEL

Step 11 Submit Required Reports

Manufacturers must submit the following reports to EPA if applicable

1 End-of-model year phase-in report for the applicable phase-in time period In general the report is required for the first two phase-in model years and can be in the format of a

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 31: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 15 of 18

spreadsheet that shows a breakdown of individual engine families compliance status US sales total company US sales and percentage compliance status within that appropriate model year

2 End-of-model year Averaging Banking and Trading (ABT) report (see recommend format in Guidance 2)

3 Periodical and end-of-model year PLT report (see Step 9)

Failure to submit the required reports within the required time period may result in suspension or revocation of a certificate

Manufacturers must submit quarterly production reports and an End-of-Model Year corporate average report to CARB

Step 12 Provide Maintenance Instructions to Purchasers of Vehicles Provide Warranty Service Information Submit Defect Reports and Conduct Vehicle Recalls if Any

Maintenance Instructions

40 CFR sect1051125 provides the detailed requirements for written maintenance instructions that a manufacturer must provide to an ultimate purchaser of the vehicle The application must contain the same maintenance instructions you provide to your customers

Please note you may not schedule critical emission-related maintenance within the minimal useful life period for the components specified in 40 CFR sect1051125(a)(3)

The EPA and CARB require you to submit the ownerrsquos manual that contains your warranty statement and maintenance instructions to the EPACARB when it is available Instead of submitting hard copies you may provide us with electronic copies via CDs or email or access via an Internet link to that information

Warranty Requirements

Requirements for warranty including warranty period components covered scheduled maintenance limited applicability and aftermarket components are found in 40 CFR 1051120 You are required to describe in the ownerrsquos manual the emission-related warranty provisions that apply to your vehicles engines

Defect Reports and Recalls A certifying manufacturer must track warranty claims parts shipments and any other information that may indicate possible emission-related defects You must include a description of your tracking approach in your application for certification You must investigate possible emission-related defects and send Defect Reports (DR) when the number of defects reaches the applicable threshold in the following table is reached (Ref 40 CFR sect1068501)

If EPA determines your vehicles or engines do not conform to the applicable regulations you must submit a remedy plan within 60 days of EPArsquos notice and remedy those non-compliance vehicles or engines at your expense

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 32: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 16 of 18

Thresholds for Initiating Investigation and Filling DRs

Rated Power Component Thresholds (ref 40 CFR 1068501(e)amp (f))

Investigation Filling DR

lt 560 kW

After-treatment Devices including Catalytic converter

2 or 2000 units whichever is less

0125 or 125 units whichever is less

Other emission related components

4 or 4000 units whichever is less

0250 or 250 units whichever is less

euml 560 kW All emission related components

1 or 5 units whichever is greater

05 or 2 units whichever is greater

Reference 40 CFR sect1068 501 ndash540 (wwwaccessgpogovnaracfrcfrhtml_00Title_4040cfr1068_00html) 1068501 How do I report engine defects 1068505 How does the recall program work 1068510 How do I prepare and apply my remedial plan 1068515 How do I mark or label repaired engines 1068520 How do I notify affected owners 1068525 What records must I send to EPA 1068530 What records must I keep 1068535 How can I do a voluntary recall for emission-related problems 1068540 What terms do I need to know for this subpart

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

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ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 33: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 17 of 18

Attachment 1 List of Questions for New Manufacturers

To determine your manufacturer status for EPArsquosCARBrsquos emission certification program please answer the following questions

1) What are the specific details of the vehiclesengines that you intend to certify such as vehicleengine type fuel type (gasoline diesel) exhaust and evaporative emissions control devices etc Please provide brochures pictures copies of owners manuals repair manuals warranties emission labels and any sales or promotional information available to the public or other readily available materials which would be useful in explaining your products

2) How will your products be manufactured Provide a brief description of the manufacturing process for these vehiclesengines including how when where and by whom the vehiclesengines are initially manufactured or assembled how when where and by whom the vehiclesengines will be modified (if applicable) following initial assembly Also describe briefly how when where and by whom the vehiclesengines will be tested for emissions Briefly describe the test facility to be used for certification testing including the type of dynamometer used and the test procedures used for certification testing

3) What are the anticipated combined US sales of vehiclesengines you intend to certify during the model year in question Please provide breakdown sales numbers for each vehicle or engine category (such as ATVs off-highway motorcycles etc)

4) Is your company linked to any other automobile manufacturing or importing company For example does your company lease operate control supervise or own part of another company which manufactures imports or certifies recreational vehicles Does some other company lease operate control supervise or own part of your company If so what is the name of the company the percent ownership and the companys projected combined US sales of all recreational vehicles for the model year

5) If the original manufacturer of the vehicles that you intend to certify makes production changes during the model year after certification how will this information be made available to EPACARB for updating the application for certification you must submit to obtain your certificate of conformity Describe the method used by the original manufacturer to notify you of any running changes made to the vehicle

6) What assurances do you have of the durability of your emission control systems How do you plan to demonstrate to the US EPACARB that the control system technology described in your application which you intend to certify will meet emission standards throughout the specified useful life period

7) What assurances do you have to confirm that production vehiclesengines will be identical in all material respects to the motorcycles described in application for certification

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

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ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

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ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

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ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

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ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 34: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Page 18 of 18

8) Have you derived or will you derive deterioration factors (DFs) from the mileage accumulation and associated testing of a durability-data or do you request to use EPA-assigned deterioration factors for the model year you wish to certify

9) Are you aware of your obligation as a manufacturer to warrant and will you warrant the emission control system for the useful life of the vehiclesengines in accordance with the warranty requirements set forth in Section 207(a) of the Clean Air Act (42 USC 7541(a))

10) How do you plan to demonstrate to the US EPA that in-use emission non-compliance problems if any will be corrected in a timely manner Provide a detailed description regarding your plans to track the vehiclesengines sold in the US to handle customer complains to track warranty claims and to submit required Defect Reports to the US EPA

11) Are you an authorized representative for this manufacturer Please appropriate documentation such as your contractual agreement with the manufacturer that provides you with the authority to work with that manufacturer or a letter on manufacturer letterhead signed by a high-level official from that company

Revision 71604

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 35: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Workshop One Guidance 1 of 3 Attachment 2 DRAFT Page 1 of 2

Table 1 ATV Emission Standards and Test Requirement for 2006 and Later MY Exhaust Emissions

Standard Type Emission Standards Phase-in MY and Requirement

Reference for Test Procedures and Driving Schedule

Min Useful Life

Test Fuel amp Lubricants NoteHC+NOx CO

Vehicle Chassis Standards (gkm)

2006 50 2007 and later 100

Vehicle Chassis Dyno Equipment amp Procedures 40 CFR Part 86 Subpart E amp F Test Duty Cycle 40 CFR 86 App I (c)

Engine Dyno Equipment amp Procedures 40 CFR 1065 Test Duty Cycle lt100cc 1051615(d) lt225 cc 1051145(b)(2) euml225 cc 1051145(b)(2)

10000 km or 1000 hr or 5 yr whichever comes first

40 CFR 1065 Subpart C

bull ABT is allowed

bull No early emission credit

bull An EF certified to FELs must have production line test

Standard 15 35 Max FEL for ABT 200 Optional Engine Test Standards (gkW-hr)

lt 100 cc Standard 250 500 Max FEL for ABT 400

lt225 cc Standards 161 400

1 2006 50 2006 2007 and 2008 100

2 Not applicable after 2008

Max FEL for ABT 322

euml225 cc

Standards 134 400

Max FEL for ABT 268

Evaporative Emissions

Equipment Unit HC Phase-in MY Test Procedure Min Useful Life Note

Fuel Tank gm2day at 82)F 15

2008 and Later 100

40 CFR 1051515

Same as above

bull ABT is allowed for tanks only

bull Certification by design is an option Fuel Hose gm2day at 73)F 15

Pre-conditioning sect1051501(c)(2) Permeation Test 40 CFR 1051810 (SAE J30)

Reference amp Notes bull sect1051107 sect1051615(a) and sect1051145(b) ATV exhaust emission standards bull sect1051110 ATV evaporative emission standards bull sect1051245 Design based certification for tanks and hoses bull HC stands for 1) THC if use gasoline and LPG 2) NMHC if use natural gas and 3) THCE if use alcohol fuel bull EF Engine Family-A group of vehicles with similar emission characteristics as specified in sect1051230 bull FEL Family Emission Limit bull ABT Averaging Banking and Trading

Revision 71604

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

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ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

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ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

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ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

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ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

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ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

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ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

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ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

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ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

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ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 36: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

1 Full Test Procedure

begin with new tank

preconditioningfuel soak28 plusmn 5 CE10 fuel

20 weeks

use final permeationtest result for certification

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

fuel soak 28 plusmn 5 C E10 fuel

20 weeks

final permeation test run gasoline or E10 fuel

28 plusmn 2 C

Pressure Cycling 10000 x -05 to 20 psi

UV Exposure 24 Wm

Slosh Testing 1 million cycles

E10 fuel

Durability Testing

2

2 Base Test with DF

begin with new tank

preconditioning fuel soak28 plusmn 5 CE10 fuel

20 weeks

baseline permeation test run gasoline or E10 fuel

28 plusmn 2 C

adjust baseline test result with

DF to determine certification level

The deterioration factor (DF) is the difference between the baseline and final permeation test runs in the full test procedure

This soak time can be shortened based on the length of soak duringdurability testing

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 37: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 1 of 14

Recommended Application Formatfor

Certification of Off-highway Motorcycles and All-terrain Vehicles

To expedite review of your application for certification the US Environmental Protection Agency (EPA) and California Air Resources Board (CARB) strongly recommend that you adopt the standardized application format presented in this Guidance While other formats may be acceptable they may result in longer EPACARB review time

The recommend application format is based on the requirements specified in 40 CFR sect1051 (published on November 8 2002 and are subject to change through future regulatory amendments) and corresponding CARBrsquos Standards and Test Procedures (CaSTP) In this guidance citations to 40 CFR sect1051 shall also mean references to the corresponding CaSTP for the same requirements unless noted otherwise

Please note that EPA and CARB regulations differ in certain requirements (eg definition of ATV alternate useful life alternate test schedules assigned DFs emission standards and measurement units etc) For vehicles intended for sale in California manufacturers must obtain separate certification from CARB For these vehicles the term ldquoEPACARBrdquo as used throughout this guidance document shall mean that any applicable certification requirements and agency action must be separately but concurrently addressed to and ruled on by EPA and CARB

July 21 2004

Certification and Compliance Division Office of Transportation and Air Quality California Air Resources Board US EPA

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

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ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 38: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 2 of 14

Recommended Application Format

Part A Common Information Part B Individual Engine Family Application

1 Request for Certification 2 Correspondence and Communications 3 Data Summary Sheet (DSS) 4 40 CFR sect1051205 (a) to (s) Application Requirements 5 Averaging Banking and Trading (ABT) Requirements if any 6 Additional California Requirements (reserved)

Part A Common Information (to be submitted with your first application for a new model year and must be updated when changes occur before and after certification)

You may submit certain information which is common to more than one engine family (EF) in Part A rather than in Part B for an individual EFrsquos application If you do so you may reference the information rather than submit it within Part B application We have made suggestions in each section of Part B below of information that can usually be submitted as common information

Part B Individual Engine Family Application (to be submitted for each engine family for a new model year and must be updated when changes occur before and after certification)

1 Request for Certification

The request for an EPA certificate andor CARB Executive Order (EO) should contain the following information

bull Manufacturerrsquos legal name bull Name of the engine family that you intend to apply for a certificateEO bull All applicable vehicle categories (see Part B4(a)) within the EF bull Statements that the EF complies with all applicable EPACARB regulations bull Primary certification contact for questions name title phone and email addresses bull Signature of an authorized company representative

Advice for Submittal

bull Organize the above information as a cover letter Note CARB requires an original signed cover letter to be submitted in paper format

bull Identify your companyrsquos primary certification contact by For questions call bull In general you should plan for at least 30 days for EPACARB to review and issue a

certificateExecutive Order from the time a complete application is submitted However if you have a special need for an expedited review please indicate in the letter

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 39: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 3 of 14

2 Correspondence and Communications

Information to be Included

bull Names titles phone numbers fax numbers e-mail addresses and areas of responsibility of all persons authorized to be in contact with EPACARB compliance staff At least one US contact must be provided

bull Dedicated Email address (one per company) for EPA to send certificates and any other official documents

bull US mail address where EPA may mail official document if Email is not appropriate path

bull US mail address where CARB will mail official documents if different than above

Advice for Submittal

bull Supply complete list of contacts in Part A bull Create a dedicated email address to receive your certificate We strongly recommend that

you use the format certificate[company]com for your company to receive certificates and any other official documents

3 Data Summary Sheet (DSS)

The Data Summary Sheet (DSS) (See Guidance 2 Attachment 1 DSS) is the printout summary of data that you entered into the EPACARB database for this engine family prior to preparing this application (A separate guidance regarding submitting data into EPACARB database will be provided when the database is ready) The DSS is comprised of the following sections

1 General Information 2 EPACARB Emission Standards and Certification Levels 3 Engine Family Description 4 Exhaust Emission Control Information 5 Exhaust Emission Data Vehicle and Test Data 6 Permeation Emissions Control and Test Data 7 Models Covered

Including the DSS in the application not only reduces submission of redundant information that is required in other sections of Part B but also provides manufacturer another chance to review the data entered into EPACARB database

[Note Before the planned EPACARB database is fully functional manufacturers may need to fill out the DSS]

4 40 CFR sect1051205 (a) to (s) Application Requirements

(a) Engine Family (EF) Description (Ref 40 CFR sect1051205(a))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 40: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 4 of 14

Describe the engine familys specifications and other basic parameters of the vehicle design List the type of fuel you intend to use to certify the engine family List vehicle configurations and model names that are included in the engine family

Information to be included bull Engine family name bull All applicable EPACARB vehicle categories within the EF

frac34 ATVA (all-terrain vehicle meeting CARBrsquos 13 CCR 2411 definition and EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) definition)

frac34 ATVB (all-terrain vehicle meeting EPArsquos 40 CFR sect1051801 All-Terrain Vehicle (1) and (2) definition but not CARBrsquos 13 CCR 2411 definition)

frac34 OFMC (off-highway motorcycle) frac34 ENG (engine-only certification see 40 CFR sect105120 not allowed under CARB

regulations) or frac34 UTV (off-road utility vehicles covered by 40 CFR sect10511 (a)(4))

bull Any new technology applied bull Fuel type(s) (operating fuel(s)) gasoline liquefied petroleum gas (LPG) methanol or

natural gas (NG) etc bull The EFrsquos specifications

frac34 engine type combustion cycle displacement(s) rated power and toque the number and arrangement of cylinders appropriate bore diameter and other basic vehicle parameters

frac34 engine cooling medium (air water oil etc) frac34 fuel system configuration use SAE J1930 abbreviations

CARB - Carburetion TBI - throttle body fuel injection MFI ndash multi-port fuel injection SFI - sequential MFI DGI - direct gasoline injection AIR - secondary air injection PAIR - pulsed AIR etc

frac34 method of air aspiration (natural turbo charge supercharge etc) bull Models covered (commercial model names not manufacturerrsquos model code names)

Advice for Submittal

bull Reference the appropriate sections on DSS for information required above bull Alternatively manufacturers may choose to provide two tables one for the models for

CARB certification and the other for EPA certification

to be certified under CARB SORE or LSIE regulations

(b) Emission Control Systems and Auxiliary Emission Control Devices (AECD) (Ref 40 CFR sect1051205(b))

Explain how the emission-control systems operate

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 41: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 5 of 14

(1) Describe in detail all the system components for controlling exhaust emissions including auxiliary emission-control devices and all fuel-system components you will install on any production or test vehicle or engine Explain why any auxiliary emission-control devices are not defeat devices (see 40 CFR sect1051115(f)) Do not include detailed calibrations for components unless we request them

(2) Describe the permeation emission controls

For Exhaust Emission Control

Information to be Included bull The detailed description of your catalyst converters (type number location arrangement

(ie parallel or series) volume compositions etc) bull The number location arrangement (ie parallel or series) and type of the sensors if

any bull Brief description of fuel-system bull Brief description of Exhaust Gas Recirculation (EGR) as applicable bull Brief description of air injection system as applicable bull Brief description of any other exhaust emission control system bull Part numbers of emission related component (part numbers as stamped on the

component not the stock or inventory numbers)

Use prefix ldquo2rdquo and suffix ldquo(2)rdquo to designate parallel and series arrangements respectively (eg 2OC means two oxidizing catalytic converters in a parallel arrangement O2S(2) means two oxygen sensors in a series arrangement one before and one after the catalytic converter)

Advice for Submittal bull You may reference the appropriate sections in the DSS for some information required

above bull You may organize the emission related part data in a table format bull You may use schematics to illustrate control devices or strategies if applicable bull You may place any general descriptions or schematics in Part A bull If you consider any of the catalyst information (volume composition or ratio of the

precious metals etc) to be confidential create a code such as ldquocatalyst Ardquo in a public file (name it FOI_[EF name]pdf) of the application and describe the catalyst associated with the code in the confidential copy (with name CBI_[EF name]pdf) Both files must be submitted to EPACARB

For EvaporativePermeation Emission Controls (Ref 40 CFR sect1051245)

Information to be Included

bull Permeation family or group name if any bull Fuel tank(s) material wall thickness total inside surface area and treatment

approachcontrol technology bull Fuel lines material wall thickness total inside surface area and control technology bull Detailed description of any other means or strategies used to prevent permeation

emissions

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 42: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 6 of 14

bull Description of crankcase emission control

Advice for Submittal

bull You may reference the appropriate DSS sections for the information required above bull Use schematics to illustrate crankcase tanks or hoses emissions controls as applicable

and place any common descriptions or schematics in Part A bull For permeation emission control devices that are used in multiple engine families you

may reference a complete list of breakdown of your permeation emission control devices or strategies in Part A rather than re-describe them within each application for an individual engine family

Auxiliary Emission Control Devices (AECD)

Information to be Included

All AECDs installed on any applicable vehicles including the sensed and controlled parameters A detailed justification for each AECD which results in a reduction in effectiveness of the emission control system and rationale why the AECD is not a defeat device as defined under 40 CFR sect1051115(f)

Advice for Submittal

bull You may make a table such as below to list all AECDs sensors sensed and controlled parameters and justifications involved in the engine family

AECD Sensed Parameter Sensor

Controlled Parameters Justification

Rationale Volt High Volt Low

bull You may reference a complete breakdown list of AECD tables for a model year in Part A rather than re-describe them with each engine family

bull If you consider any of the AECD information to be confidential create a code in the public copy of the application and describe the confidential information associated with the code in the confidential copy As mentioned above both copies must be submitted to EPACARB

(c) Emission Data VehicleEngine (EDV) Description (Ref 40 CFR sect1051205(c))

Describe the vehicles or engines you selected for testing to satisfy the certificationrequirements and the reasons for selecting them

Information to be Included

bull Manufacturerrsquos explanation for EDV selection (including justifications that the selected EDV meets the selection requirements under both EPACARB regulations eg justify

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 43: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 7 of 14

why a federal vehicle model selected for EDV for the EF meets CARB requirements or vice versa why a California vehicle model selected for EDV for the EF meets EPA requirements)

bull Data type (new carryover or carry across) bull EDV ID (Vehicle Identification Number (VIN) or manufacturerrsquos ID) bull EDV configuration bull EDV model name bull EDV rated horsepower rpm and rated toquerpm bull EDV displacement bull EDV transmission type bull EDV NV bull EDV curb mass bull EIM bull Road Load (nt) bull Test number bull Test fuel bull Exhaust emission control systems bull Maintenance performed

Advice for Submittal

bull You may place a complete breakdown of your EDV information for a model year in Part A and refer the page number of Part A in this section

bull You may reference the appropriate DSS sections for test vehicleengine information requested above

(d) Alternate or Special Test Procedure Description (Ref 40 CFR sect1051205(d) 235 amp 501)

Describe any special or alternate test procedures andor special test equipment you used

Please note advanced EPACARB approvals are required before taking action

Information to be Included

Description of all EPACARB-approved special or alternate test procedures special test equipment durability procedures or driving schedules you used for exhaust or permeation emission tests

Advice for Submittal

bull Include a copy of EPArsquos and CARBrsquos approvals in the application when a special or alternate test procedures andor special test equipment is used or

bull Reference the EPArsquos andor ARBrsquos approval numbers here if any

(e) Durability Test Procedure Description (Ref 40 CFR sect1051205(e) and 40 CFR sect1051520)

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 44: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 8 of 14

Describe how you operated the test vehicle or engine prior to testing including the duty cycle and the minimum testing distance or minimum numbers of engine operating hours to stabilize the emission levels number of tests conducted and any scheduled maintenance you performed

Please note advanced EPA and CARB approvals are required prior to use of any special or alternate test procedures andor special test equipment

Exhaust Emissions Durability Procedures (40 CFR sect1051520)

Note EPA-designated small-volume manufacturers (SVMs) may request to use EPArsquos assigned deterioration factors (DFs) instead of performing durability tests California regulations and test procedures require durability demonstration for every EF but unlike EPArsquos do not provide for the use of assigned DFs SVMs should discuss with assigned CARB staff to obtain advance CARB approval on how CARBrsquos durability requirements will be met before any certification tests are conducted Failure to do this can significantly delay CARB certification andor result in a denial of the manufacturerrsquos certification request

Information to be Included

bull Deterioration Factor (DF) data type (new carryover carry-across or EPA assigned DFs for SVMs)

bull If your durability data vehicle (DDV) is different than EDV (in certain carryover or carry-across cases) please provide the same information as required in Part B4(c) for the DDV

bull Description of the durability procedure mileage accumulation procedure minimum and total testing distancehours number of tests conducted emission levels from each test and any scheduled maintenance performed

Advice for Submittal

bull Provide the durability procedure descriptions in Part A and place a reference in this section

bull Reference appropriate Section(s) on DSS for deterioration factors and test results bull If new durability data is not provided explain the reason and identify the source of data bull Provide durability data and information in a table format

Permeation Emissions Durability Procedures (40 CFR sect1051515(c))

Information to be Included bull Specifications of durability tankshoses bull Specifications of a canister(s) if any bull Description of any modifications made to EPA standardized procedure if any

Advice for Submittal bull Provide the durability procedure descriptions in Part A Then provide a reference in this

section

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 45: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 9 of 14

bull Reference the DSSB6 for all deterioration factors bull If new durability data is not provided explain the reason and identify the source of data

(f) Test Fuel Specifications (Ref 40 CFR sect1051205(f))

List the specifications of the test fuels to show that they fall within the required ranges

Information to be Included bull Lists of the test fuel specifications for both exhaust and permeation emissions

Advice for Submittal bull List the test fuel specifications for both exhaust and permeation emissions side-by-side

with the required range as specified in the applicable regulations bull Place the above comparison lists in Part A and reference them in this Section

(g) Useful Life of the Engine Family (Ref 40 CFR sect1051205(g))

Specify the useful life of the engine family

For EPA certification in general the minimum useful life is 10000 kilometers 5 years or 1000 hours whichever comes first Five years should be used when the vehicle is not equipped with an odometer or hour meter

For CARB the useful life is fixed at 5 years10000 km any other useful life such as 1000 hours or any other alternative use full life that may be permitted under EPA regulations is not allowed for California certification Therefore vehicle models intended to be certified for California-only or 50 states must comply with CARB useful life requirement

(h) Maintenance and User Instructions (Ref 40 CFR sect1051205(h) and 40 CFR sect1051125)

Provide the proposed maintenance and use instructions for the ultimate buyer of each new vehicle of this engine family as specified in 40 CFR sect1051125

Information to be Included bull Critical-emission related maintenance bull Recommend additional maintenance bull Special maintenance bull Non-critical-emission related maintenance bull Maintenance that is not emission-related bull Emission related part number summary form and sources for parts and repairs

Advice for Submittal

bull Make a table to list all parts that are emission related with sources for parts and repairs bull Provide us with the Ownerrsquos Manual for the new vehiclesengines when available

Submit the final ones in hardcopy

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 46: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 10 of 14

(i) Emission-Related Installation Instructions (Ref 40 CFR sect1051205(i) and 40 CFR sect1051130)

Information to be Included

The proposed emission-related installation instructions for each model covered by this application if you sell engines for someone else to install in a recreational vehicle (see 40 CFR sect1051130)

Advice for Submittal

bull Discuss with EPACARB in advance on any issues raised on emission relatedinstallation instructions

bull You may reference a complete breakdown of emission-related installation instructions for a model year in Part A and place a reference page number here

(j) Vehicle Engine Emission Control Information (VECI) Label (Ref 40 CFR 1051205(j))

Propose an emission control information label

Information to be Included bull As specified in 40 CFR sect1051135 (c)

Advice for Submittal bull Discuss with EPACARB in advance if you propose any changes other than

specified in 40 CFR sect1051135 (c) bull Present a photocopy of the VECI label in the same size as the actual label bull You may reference a complete set of photocopies of the labels for a model year in

Part A

(k) Emission Data (Ref 40 CFR sect1051205(k))

Present emission data to show that you meet emission standards

Information to be Included

bull Exhaust emission data for HC NOx HC+NOx and CO before and after applyingdeterioration factors as specified in 40 CFR sect1051205(k)(1)

bull Permeation emission test data for HC before and after applying deterioration factors as specified in 40 CFR sect1051205(k)(2)

Advice for Submittal bull Reference appropriate DSS section(s) for information requested bull If new emission data is not provided in certain cases such as existing emission data carry-

over carry-across or certify by design (Ref 40 CFR sect1051235 amp 245) explain the reason and identify the sources of data

(l) All Test Results (Ref 40 CFR sect1051205(l))

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 47: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 11 of 14

Report all test results including those from invalid tests or from any nonstandard tests (such as measurements based on exhaust concentrations in parts per million) The records of all test results should include a description of test parameters and special test procedures that are applicable to the vehiclesengines covered by the certificate of conformity

Information to be Included

bull All test results and calculations bull EDV preparation and starting procedures bull Service accumulation and emission stabilizing procedures bull Driving scheduleduty circles bull Shift schedules (list EPACARB shift schedule number and shift speeds) bull Dyno loading information (roadload coefficients as appropriate indexed by the

vehicle characteristics (models equivalent inertia mass (EIM) etc) bull Permeation testing parameters bull Special test procedures if any bull Special test equipment if any

Advice for Submittal

bull Upon request submit copies of raw test logs and any other raw records used in certification testing including testing dates numbers and distances raw emissions data and calculations and a description of all maintenance performed during a test

bull Keep all certification test related records on file for at least 5 model years

(m) Deterioration Factors (DFs) (Ref 40 CFR sect1051205(m))

Identify the engine familys deterioration factors and describe how you developed them Present any emission test data you used for this

Please note separate DF calculations and DF(s) for EPA certificate and California EO may be required due to EPACARB regulations differ in the following (a) definition of DFs (EPA additive for without aftertreatment and multiplicative for

with aftertreatment CARB multiplicative in all cases) and (b) possible different useful lives (EPA minimum 10000 km1000 hours5 years

alternatives may be allowed CARB 10000 km in all cases)

Information to be Included bull List exhaust DFs for HC NOx CO bull List permeation DFs of HC for fuel tanks and fuel hoses separately bull Provide all emission test data that are used for developing the above DFs bull Describe how the DFs were developed if an alternative durability procedure is

applied

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 48: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 12 of 14

bull Obtain advanced approvals from EPACARB for any alternative durability procedure

bull Reference appropriate DSS section(s) for information required above bull Provide any general information in Part A

(n) Adjustable Operating Parameters and Other Adjustments (Ref 40 CFR sect1051205(n))

Describe all adjustable operating parameters and other adjustments

Information to be Included (Ref 40 CFR sect1051115 (c) and (d)) bull The nominal or recommended setting bull The intended physically adjustable range including production tolerances if they

affect the range bull The limits or stops used to establish adjustable ranges bull The air-fuel ratios or jet chart specified in 40 CFR sect1051115(d)

Advice for Submittal

bull Organize the above required information by a table such as below when appropriate

Adjustable Parameters

Nominal Setting

Adjustable Range

Tamper Resistance Method

Approval Reference

bull You may reference a complete breakdown of adjustable operating parameters for a model year in the Part A - Common Information and place reference number here

(o) Statement of Compliance ndash Test Vehicles (Ref 40 CFR sect1051205(o))

State that you operated your test vehicles or engines according to the specified procedures and test parameters using the fuels described in the application to show you meet the requirements of this part Separate statements are required referencing EPA and CARB procedures and requirements respectively

Advice for Submittal

bull Provide the required compliance statement in your cover letter

(p) Statement of Compliance ndash Engine Family (Ref 40 CFR sect1051205(p))

State unconditionally that all the vehicles (andor engines) in the engine family comply with the requirements of this part other referenced parts and the Clean Air Act Separate statements are required referencing EPA and CARB regulations test procedures and related requirements respectively

Advice for Submittal

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 49: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 13 of 14

bull Provide the required compliance statement in your cover letter

(q) Projected USCalifornia Sales (Ref 40 CFR sect1051205(q))

Include estimates of US-directed production volumes

Information to be Included bull A list of projected US sales for each model of the engine family bull Organize the data in a table such as

Model Name US Sales Number NoteCalif 49 States Total

bull Note competition model sales if included in the FEL bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit the sales information only in the CBI copy of your application

(r) Emission Sampling Method (Ref 40 CFR sect1051205(r))

Upon request by the EPACARB manufacturers must show us how to modify your production (customer) vehicles to measure emissions in the field (see 40 CFR sect1051115 (b))

(s) Other Information (40 CFR sect1051205(s))

Information to be Included bull Phase-in plan for the first model year of the phase-in (Not applicable to CARB) bull Copy of your application fee filing form (Not applicable to CARB) bull Copy of a CARB EO if apply for ldquoCalifornia-onlyrdquo certificate (Not applicable to CARB) bull Any additional information that you may consider to help us to evaluate your application

Advice for Submittal bull Organize the phase-in sales data in such a way to show projected compliance with

any applicable implementation schedules or minimum sales requirements The plan should indicate which EFs are part of the phase-in requirements and which are not The plan should also include the rate of compliance and a determination that the phase-in implementation schedule will be met

bull Indicate competition vehicle sales involved in the FELs if any bull Place the phase-in compliance plan in Part A bull Projected sales may be considered confidential If you wish confidential treatment of

these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

5 Averaging Banking and Trading Requirements (40 CFR sect1051701-735) if Required

Last revision 71604

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 50: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 of 3 DRAFT 14 of 14

You need to provide information requested in this section only if you chose to take corporate emissions averaging andor banking andor trading options to certify to a manufacturer specified engine Family Emission Limit (FEL) based on 40 CFR sect1051701-735 or CARB designated standards

CARB regulations allow averaging but not banking or trading The use of banked or purchased credits are not allowed in a CARB averaging compliance plan CARB sales not 50-state sales must be used in the CARB averaging compliance plan A separate CARB compliance plan is required

Information to be included bull A statement of your believe that your corporate average emission levels will comply with

the applicable standards bull Detailed calculations of average emission levels and credits balance based on projected

production (see sample format attached)

Advice for Submittal and record keeping

bull You may reference your statement and a complete breakdown of ABT plan for a model year in the Part A for common information and place reference number here

bull Projected sales may be considered confidential If you wish confidential treatment of these projected sales submit an additional CBI copy of your application with the sales figures and place a reference to the CBI in the public copy

bull You are required to maintain organized paper records containing at least the following for three years from the due date for the end-of-model year report frac34 Model years and EFs involved frac34 Family Emission Limits (FEL)CARB designated standards frac34 Useful life for individual EFs frac34 Projected US-directed production volume for the model year frac34 Projected California-directed production volume for the model year frac34 Actual US-directed production volume for the model year frac34 Actual California-directed production volume for the model year

bull You are required to submit detailed calculations of the average emission levels and credits balance based on actual production within 120 days of the end of your model year

6 Additional California Information (Reserved)

Attachments 1 DSS Template 2 Sample of ABT forms 3 Sample Application (to be developed after receiving feedback from manufacturers for this

draft)

Last revision 71604

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 51: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 1 Attachment 1 -Draft - 1 of 2

Data Summary Sheet (DSS)

DSS1 General Information (Model Year ) Engine Family Name Application Type New Correction Running Change

Manufacturer SVM Yes No Sales Area 50 States 49 States California Only

DSS2 Emission Standards and Certification Levels (Emissions with DFs)

Exhaust Emissions (Unit gkm gbhp-hr gkW-hr Permeation HC Emissions (Unit (gm2day)

Vehicle Evaporative Emissions (Unit gtest) (CARB only)

Air Pollutant HC NOx HC+NOx CO Fuel Tank Fuel Hoses Diurnal Hot Soak

Certification Level

Emission Standard

Family Emission Limit

DSS3 Engine Family Description Category ATVA ATVB OFMC ENG UTV Fuel Type Gasoline LPG NG Other

Engine Type Reciprocating Rotary Turbine Other Engine Cooling Media Air Water Oil Other

Combustion Cycle 4-Stroke 2-Stroke Other Useful Life

Cylinder Arrangement Inline Vee Flat Other New Technology No Yes technology explanation

Number of Cylinders Valves per Cylinder

DSS4 Exhaust Emission Control Information (use SAE J1930 technology abbreviations) CatalyticConverter No Yes Number of catalytic converter (s)

Catalyst Configuration Parallel (P) Series (S)Catalyst Type Oxidation (OC) Three-way (TWC)

P+S OC+TWC)

Exhaust Gas Recirculation (EGR) No Yes EGR Type Electronic Controls ECM Other

Air Injection PAIR AIR O2S HO2S Other

Fuel System TBI MFI SFI DGI Carburetor Other

Method of Air Aspiration Natural SC TC CAC SAA TAA

DSS5A Exhaust Emission Data VehicleEngine (EDV-1) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkW-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 52: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 1 Attachment 1 -Draft - 2 of 2

DSS5B Exhaust Emission Data VehicleEngine (Optional EDV-2) and Test Data EDV ID (VIN) Useful Life

New Carryover from EF Test Date

Test Type Emission Test Results

gkm gbhr-hr gkw-hr

Assigned DF NA EPA SVM ARB SVM

Configuration HC NOx HC+NOx CO Test Fuel Indolene California Phase 2 Model Name

Rated Power Emission Control device

Displacement (cc)

Transmission DDV information

NV Ratio

Curb Mass DF Manufacturer notes

EIM EPA

Cert level

First Test at Unit km hr CARB

DF Last Test at Unit km hr Cert level

DSS6 Permeation Emissions ControlTest Data (Evap Family name if any ) Certify by Emission Testing

Equipment Material Thickness (mm)

Total Inside Area (m2)

Test Data (gm2day) Evap Perm Test Type Carryover from MY EF

DF (gm2day) New EPA DF for SVM Carryover MY EF

Emissions with DF (gm2day)

Fuel Tank

Fuel line

Manufacturer Notes

Certify-by-Design

Fuel Tank Fuel tank permeability control technology applied is 40 CFR sect1051245 Table 1 control technology (i) (ii)

Fuel line Fuel lines permeability control technology applied is 40 CFR sect1051245 Table 2 control technology (i) (ii)

DSS7 Models Covered

Make Model Engine Code

Vehicle Category

Bore Stroke

(mmmm)

Displacement (cc)

Rated Power (hp)

Rated Toque (nt-m)

Rated Speed (rpm)

Curb Mass (kg)

Trans (M5 A3 etc)

Sale Areas

1

California ATV Specification (Category ATVA) ( use Yes or No to answer)

Model 50 ldquo or Less in Width

4 Low Pressure

Tires

Seat Straddled by Operator No Passenger Handlebar Max Payload

350 lb CARB ATV

Certification

1 Specify if (1) California only (2) 49-state or (3) 50-state

EmilyCA-certATVWorkshop-7-21DSS(Revised July19)-EPAdoc

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 53: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 2 Attachment 2 - Draft-Company Averaging Banking and Trading Report

For EPA CARB (check one) (Page __of __) Company NameModel Year ABT Category TypeABT Pollutant HC+NOx HC NOx FEL Emmiissiossionn UnitABT E Type

HMC OFMC ATVNMHC+NOx ATV (Engine)NMHC CO g kmE xhaust gkW-hrEv aporative Report Type OFMC (Engine)Manufacturer Notes OFMC+ATV g bhp-hr gm2day

Preliminary End of MY Report Da te

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Engine Family Name

Family Emission

Limit

Useful Life (Unit )

Family Production

Units Model Name Rated Power

Model Production

Units

CARB Report only Credit Used For

(A B or T)Designated HC (gkm)

Designated HC+NOx (gbhp-hr)

Emission Standard

Averaging Emission Level = [(2)x(3)x(4)][(3)x(4)] =

Credit (EPA only) =

Company credit balance calculation (not applicable to CARB)

Note Separate reports and calculations are required for EPA and CARB due to different standards (eg HC or HC+NOx) different units (gbhp-hr or gkW-hr) different US and California sales different useful lives no credits use allowed for CARB compliance For CARB OFMC and chassis-certified ATV can be in the same averaging set because they meet the same gkm standards)

Revision 71604

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 54: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 3 of 3 -- Draft -- 1 of 5

Questions and Answers For ATVOFMC Workshop July 21 2004

On November 8 2002 the US Environmental Protection Agency (EPA) published its final rules on the control of emissions from 2006 and later model year off-highway motorcycles and all-terrain vehicles (Ref 40 CFR sect1051 1065 and 1068) The Certification and Compliance Division (CCD) within EPArsquos Office of Transportation and Air Quality is charged to implement and administer these new regulations to ensure that vehicles and engines subject to these rules meet the certification and compliance requirements throughout their useful lives

On February 11 2004 the CCD notified manufacturers (Ref CCD-04-04) of the new certification and compliance program and invited manufacturers to submit questions that would be answered in an upcoming workshop for the new program We have received numerous questions in writing from the Motorcycle Industry Council (MIC) Combined with general concerns or questions received from individuals we are providing answers to those questions in the following document

General Questions

1 Are these new regulations applicable to me

If you manufacture or import 2006 and later model year off-highway motorcycles (OFMC) and all-terrain vehicles (ATV) or engines (ENG) installed in ATVs or OFMCs these new regulations are applicable to you

Please note any requirement that applies to ATVs is also applicable to off-road utility vehicles (UTV) that have a displacement less than or equal to1000 cc maximum brake power less than or equal to 30kW and maximum vehicle speed greater than or equal to 25 mph

The following table may assist you in locating the applicable certification regulations to your products

Classes of VehiclesEngines vs General Certification Regulations

Classes of VehiclesEngines (EPA Topic Contact List

wwwepagovotaqoms-conthtm)

General Certification Regulations

(Accessible from wwwgpoaccessgovecfr)

Recreational Vehicles (ATVs Off-highway Motorcycles amp Snowmobiles) and Engines ( gt 5000 rpm) 40 CFR Part 1051

Highway Motorcycles 40 CFR Part 86 Subpart E Small Non-road Spark Ignition Engines (lt 19 kW) Large Non-road Spark Ignition Engines (gt 19 kW)

40 CFR Part 90 40 CFR Part 1048

Light-duty Vehicles and Trucks 40 CFR Part 86 Subpart S Heavy-duty Highway Engines 40 CFR Part 86 Subpart A Nonroad Compression-Ignition (CI) Engines 40 CFR Part 89 Heavy-Duty Vehicle Evap 40 CFR Part 86 Subpart M

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 55: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 3 of 3 -- Draft -- 2 of 5

Marine SI OutboardPWC 40 CFR Part 91 Marine CI gt 37 kW 40 CFR Part 94 Marine SI InboardStemdrive 40 CFR Part 1045 Locomotives and Locomotive Engines 40 CFR Part 92

Referencefrac34 For definitions of Model Year OFMC ATV etc see 40 CFR sect1051801 frac34 For exemptions see 40 CFR sect10515

2 Where can I find the applicable new regulation for ATVOFMC certification and compliance

The United States federal regulations are codified in the Code of Federal Regulations (CFR) Title 40 of CFR contains environmental related regulations The new regulations applicable to the new ATVs and OFMCs emissions control program are

40CFRsect1051 Control of Emissions from Recreational Engines and vehicles40CFRsect1065 Test procedures and Equipment40CFRsect1068 General Compliance provisions for Non-road Programs

You may view or download theses regulations online via the EPArsquos web site httpwwwepagovepahomeruleshtmlcodified Hard copies of the above regulations may be ordered by calling 202-512-1800

3 Which laboratories perform the EPA tests

A list of laboratories that have the capabilities to conduct some or all of the required exhaust and evaporative emission testing is supplied by and periodically updated by the EPA The EPA does not endorse or approve test laboratories or vouch for the lists completeness The lab list may be viewed at wwwepagovotaqconsumerlablistpdf

4 Am I qualifying as a ldquoSmall Volume Manufacturerrdquo

There are two ways a manufacturer can qualify as a ldquosmall volume manufacturer (SVM)rdquo

1) By definition (Ref sect1051801) For motorcycles and ATVs a manufacturer that sold motorcycles or ATVs before 2003 and had annual US-directed production of no more than 5000 off-road motorcycles and ATVs (combined number) in 2002 and all earlier calendar years For manufacturers owned by a parent company the limit applies to the production of the parent company and all of its subsidiaries

2) By the EPArsquos designation (Ref sect1051635) If a manufacturer belongs to one of the following Small Business categories of the Small Business Administration (SBA) the EPA may designate the manufacturer as a SVM upon request

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 56: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 3 of 3 -- Draft -- 3 of 5

Ref Federal Register Vol67 No 217 1182002 Table XI C-1 Primary SBA Small Business Categories

Industry Employees Motorcycle and Motorcycle Parts Manufacturer lt500 ATV Manufacturer lt500 Independent Commercial Imports of Vehicles and Parts lt100 Non-road SI Engines lt1000 Internal Combustion Engines lt1000

Advanced EPA approval is required before taking any action to use SVM provisions in the regulations

When you apply for a new model year certificate under SVM status the EPA may ask you to provide sales numbers from the previous model years The EPArsquos computer system will also record and verify a manufacturerrsquos SVM status for each new model year

5 Where can I find the EPA guidance

The EPA Office of Transportation and Air Quality issues guidance letters (Dear Manufacture Letter or Advisory Circular previously) to manufacturers These letters provide information guidance and instructions to the regulated automotive industry on specific compliance topics and issues All guidance letters issued by the Agency may be viewed on our Web site at httpwwwepagovotaqcertdearmfrdearmfrhtm You may submit your email address to omscfeisepagov if you are interested in receiving the agencyrsquos guidance letters

The Motorcycle Industry Council (MIC) Comments and Questions (Ref Letter from Pamela Amette of MIC to EPA 41304)

6 MIC For plastic tank permeation testing as the regulation specifies the outlets of the tank must be sealed using non-permeable fittings Therefore the production gaskets petcock and fill cap are not considered to be part of the tank for the purposes of this test

EPA The fill cap is considered to be part of the fuel tank and would have to be used during permeation testing The holes that can be sealed with non-permeable fittings are those that would normally be open on a production vehicle (vent hole hole for fuel line (petcock))

7 MIC For the metal tank gasket permeation requirements we request that EPA confirm data demonstrating that a metal tank (including gaskets) meets the 15gtank m2day standard is acceptable We propose that EPA accept permeation data for the gaskets applied to the total tank surface area to meet this demonstration requirement even if the gasket material does not meet the requirements of ASTM D 814ndash95 and are larger than 1000

2mm

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 57: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 3 of 3 -- Draft -- 4 of 5

We believe that these changes are appropriate and remain consistent with the regulatory intent

EPA No The 1000 mm2 number was considered to be worst case for a design specification and is not meant to define the standard Manufacturers would have the option of performing permeation testing on their tanks rather than using this design-based certification option

8 MIC MIC also requests clarification that the ldquofuel linerdquo as specified in the permeation test procedures means the fuel lines which contain liquid fuel and any hoses containing only vapor (including vent hoses) do not need to comply with these permeation requirements

EPA Fuel lines with saturated vapor would see the same permeation rate as those filled with liquid

9 MIC MIC requests written guidelines clarifying EPArsquos policy on adjustable parameters We understand that EPA has already judged as follows

o Manufacturers do not need to ensure compliance in a mis-configuration (such as low altitude setting in high altitude or vice-versa)

o Manufacturers do not need to ensure compliance in intermediate settings unless it is physically adjustable (without anti-tampering measures) or recommended by the manufacturer

EPA MIC is correct in their interpretation for both of the scenarios above

10 MIC MIC requests a response to our letter of February 23 2004 to Mr Alan Stout regarding alternative test procedures

EPA We believe that we have already answered the question of alternative test procedures and raw gas sampling We do not believe that section 1065 needs to be changed Raw gas sampling can be used as long as manufacturers can provide data that gas sampling results are equivalent to data collected using our test procedures

11 MIC MIC requests verification from EPA that only the exhaust emissions standards must be listed on the VECI label as 1051135(c)(12) requires for ldquothe enginerdquo

EPA As you may notice the proposed tech amendment has revised 1051135 to require evaporative standards on the VECI label

12 MIC MIC will request clarification of EPArsquos policy regarding maintenance (non-emissions related non-critical emissions related and critical emissions related) Additional details regarding this clarification will be provided later

Revision (71604)

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 58: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

ATVOFMC Guidance 3 of 3 -- Draft -- 5 of 5

EPA The new Tier 4 regulations for Nonroad Diesel Engines to be published in June of 2004 have made clarifications to sect1051125 with regards to maintenance

13 MIC As MIC previously commented the NER equation should be separated for different standard classes in order to ensure that they are equitable and not misleading We look forward to working with EPA to resolve this issue

EPA The NER equation has been modified per MICrsquos suggestions for ATVrsquos over 225 cc and under 225 cc that are certified to the J1088 cycle The NER equation has also been adjusted for ATVrsquos under 100cc

14 MIC Please verify whether manufacturers will be able to download a report when the certification application is submitted

EPA Yes this function has been considered and will be built in the Agencyrsquos new certification and compliance computer system

Revision (71604)

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 59: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Technical Amendments

bull EPA will soon propose technical amendments ndash Update test procedures in 40 CFR part 1065 ndash Define characteristics for evaporative families ndash Revise and clarify permeation procedures ndash Revise equations for Normalized Emission Rates ndash Reduce useful life for youth-model ATVs and Off-highway

motorcycles ndash Allow interim raw-gas sampling for ATVs ndash Provide for adjusted value for maximum test speed ndash Revise regulatory text for consistency across programs

bull Public workshop planned for September 8-9 bull Comment period ends October 15 bull Final rule by Spring 2005

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 60: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

OFMC amp ATVE-Application Database

Integrated Certification ProcessModeling

EPA and CARB

July 21 2004

7-21-2004 OFMCATV Process and Database Requirements 1

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 61: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Overviewbull New OFMCATV e-application and

database are integral part of EPACARB certification application submittal procedures

bull New harmonized format 2006 Model Year OFMCATV certification application

bull Integrated into the new EPArsquos VERIFY System and CARBrsquos certification system

bull Will not change existing rules amp regulations7-21-2004 OFMCATV Process and Database Requirements 2

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 62: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Simple Application Format bull Simplified two part application format bull Part 1 - general engine family information

bull Part 2 - electronic engine family specific emissions database

bull Two categories for Part 1 amp Part 2 frac34 non-confidential (public) information (FOIA) frac34confidential business information (CBI)

7-21-2004 OFMCATV Process and Database Requirements 3

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 63: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

The GOAL

bull Consistent harmonized application formatbull Accurate information submittal bull Allows for faster application review bull Reduce response and turn around time bull Several submittal methods bull AutomaticSelf generation of the EPArsquos

Certificate of Conformity is possible

7-21-2004 OFMCATV Process and Database Requirements 4

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 64: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Project Timeline

bull Integrated Process Model ndash 7102004 completed

bull Data Modeling ndash August 31 2004

bull Data Requirements ndash September 30 2004

bull Beta version - November 15 2004

bull Version 1 - December 2004

7-21-2004 OFMCATV Process and Database Requirements 5

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 65: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Mfrrsquos Role

bull Understand manufacturerrsquos responsibilities

bull Understand the integrated process model bull Understand the data requirements bull Understand the data modeling

7-21-2004 OFMCATV Process and Database Requirements 6

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 66: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

How to Help

bull Involved in defining the data fields bull Involved in data submittal procedures bull Involved in testing the submittal process

bull Involved in testing the front-end product

7-21-2004 OFMCATV Process and Database Requirements 7

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 67: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Differences in ModelsEPA

bull Certification Fees bull Evaporative standardbull Exhaust standard bull Categories bull PLT warranty bull ABT bull Compliance Testing

CARB bull No cert fees bull No Evap Standardbull Different exhaust

standardbull Different categoriesbull No PLT no warranty bull Averagingbanking

only bull Confirmatory Testing

7-21-2004 OFMCATV Process and Database Requirements 8

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 68: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Process Requirements

Exh Phase-in Mfr Common Warranty Evap Phase-in EF Specific Log-in Security DF Durability ABT Cert Fees Exhaust PLT Mfr Contact Evaporative Data Security Info Handling Confirmatory FOIA pdf other FOIA CBI Running Change CBI pdf other Data Storage Field Fix Compliance Etc 7-21-2004 OFMCATV Process and Database Requirements 9

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 69: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Data Requirement(Exhaust as an example from previous page)

ExhRaw EdvConfig TestFacility

ExhCert EdvModel TestFuel

ExhDF EdvEIM TestDistanceHrs

ExhStd EdvCurbWeight TestType

ExhMileHRs EdvID TestProcedure

ExhUsefulLife COData TestID

ExhUnits AssignDF TestDate

ExhFEL ECSInformation Etc

7-21-2004 OFMCATV Process and Database Requirements 10

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 70: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Data Field(ExhRaw as an example from previous page)

Field name

Field property

Field description

HCType Character 6 thc nmhc nmog

Type of hydrocarbon

ExhRawHC (THC)

Numeric 74 00001~999999

Raw HC emissions

ExhRawCO ExhRawNOx 7-21-2004 OFMCATV Process and Database Requirements 11

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 71: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

System ArchitectureInteractive Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download

bull Planned Architecture ndash Web browser ndash Web forms (which will allow xml submittal files to be stored on desktops

until ready for EPA process)

July 14 2004 1

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 72: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Proposed System Architecturefor VERIFY

July 14 2004 2

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 73: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

System ArchitectureBatch-Mode Web-Based Data Collection

bull Requirements ndash Internet-based ndash No software to download ndash XML file must be developed by submitter ndash Gives data submitters two options

bull Option 1 User interface to submit XML batch files bull Option 2 Machine-to-machine interface to submit XML batch files utilizing web services

bull Planned Architecture ndash XML data standards ndash Web services hosted by EPA to support data XML batch file

submissionbull Option 1 provides a simple web form to submit an XML batch file bull Option 2 lets manufacturers implement their own software to interact with web services

July 14 2004 3

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 74: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Planned System ArchitectureManufacturer and ARB Interfaces

Submission Collection Compliance

EPA Data Center Research Triangle Park NC

Manufacturers bull Web-based data

collection

Web Services

Web Forms

EPA Compliance Staff Ann Arbor MI and Washington DC

Secure HTTP

Secure HTTP

Secure HTTP

Web browser

CARB Compliance Staff (In Use Compliance only)

Secure HTTP

Web browser

Common Collection Database

Integrated Compliance Database

Interactive mode Web browser

Batch mode XML and Web Services

CARB In Use Test Data bull CARB

(In Use data only) CARB

In Use test data

Secure Feed

CARB In Use test data

EPA Firewall

July 14 2004 4

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 75: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

System Architecture Prototype

bull EPA has developed a prototype to evaluate selected aspects of the planned architecture ndash Interactive web-based data collection

ndash Batch-mode (XML) data collection

ndash Data accessibility

ndash Security

ndash Other areas

July 14 2004 5

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13
Page 76: ATV/OFMC Regulations · 2016-09-22 · Competition Exemption •ATVs – The vehicle or engine may not be displayed in any public dealership – Sale of the vehicle must be limited

Develop Submittal Infrastructure (CDX)

EPA has contracted for the development of VERIFY infrastructure on EPArsquos Central Data Exchange (CDX)

bull EPAs CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data exchanges to the Agency

bull CDX provides the capability for submitters to access their data through the use of web services

bull You can find more information about CDX at httpwwwepagovcdx

July 14 2004 6

  • ATVOFMC Regulations
  • Major Steps for Certification and Compliance13
  • New Testing Facility
  • List of Qs for New Manufacturers
  • Recommend Application Format13
  • Data Summary Sheet13
  • ABT Report
  • Qs and As
  • Technical Amendments13
  • E-application and Database
  • Proposed System Architecture for VERIFY13